https://www.taxtmi.com/caselaws?id=756667 Reassessment proceedings cannot be sustained where the section 148A(b) notice rests on an incorrect factual premise, such as the mistaken assumption that no return was filed, and the transactions were already disclosed in the return. The validity of reassessment must be tested only on the reasons recorded in the original notice and the material then available; those reasons cannot later be expanded by introducing new grounds in the objections stage or in the section 148A(d) order. On that basis, the notice, the order disposing of objections, and the section 148A(d) order were unsustainable, though liberty was left open to proceed afresh in accordance with law if permissible. en-us Mon, 05 Aug 2024 00:00:00 +0530 Tue, 06 Aug 2024 10:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756667 Reassessment proceedings cannot be sustained where the section 148A(b) notice rests on an incorrect factual premise, such as the mistaken assumption that no return was filed, and the transactions were already disclosed in the return. The validity of reassessment must be tested only on the reasons recorded in the original notice and the material then available; those reasons cannot later be expanded by introducing new grounds in the objections stage or in the section 148A(d) order. On that basis, the notice, the order disposing of objections, and the section 148A(d) order were unsustainable, though liberty was left open to proceed afresh in accordance with law if permissible. Case-Laws Income Tax Mon, 05 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756667